John C. and Joan F. Stukes - Page 9




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          on 22 of those occasions (or within a day or two of the claimed             
          date for those occasions).2  The total number of miles                      
          petitioners drove the truck for the purpose of acquiring farm               
          equipment or supplies on those 22 occasions was 2,368.                      
          Petitioners did not present receipts for the actual cost of this            
          use, but we may apply the standard mileage rate to determine the            
          allowable deduction.3  The standard mileage rate for 2002 was               
          36.5 cents per mile.  Accordingly, the total allowable expense              
          for farm-related use of the truck amounted to $864.32.                      
               Petitioners’ mileage log contains three entries pertaining             
          to automobile maintenance and repair that are corroborated by               
          bank records, showing purchases of $224.99.4  In addition,                  
          petitioners submitted a credit card receipt for $100 of repairs             
          to the truck.                                                               


               2The dates of use that are matched by substantiating                   
          purchases are:  Feb. 2 and 18; Mar. 3, 13, 16, and 18; May 6, 7,            
          and 24; July 5 and 17; Aug. 5, 14 (two purchases on Aug. 14), and           
          31; Sept. 1, 2, 3 (two purchases on Sept. 3), 16, and 21; Oct. 1            
          and 10; and Nov. 29.                                                        
               3The standard mileage rate is a matter of administrative               
          convenience by which a taxpayer may compute the amount of                   
          deductible automobile expenses using a standard rate rather than            
          separately establishing the amount of an expenditure for travel             
          or transportation.  Sec. 1.274-5(j), Income Tax Regs., in part,             
          grants the Commissioner the authority to establish a method under           
          which a taxpayer may use mileage rates to substantiate, for                 
          purposes of sec. 274(d), the expense of using a vehicle for                 
          business purposes.  See Rev. Proc. 2001-54, 2001-2 C.B. 530.                
               4These dates are:  Mar. 13, Mar. 16, and Nov. 29.  The                 
          corresponding claimed expenses are $141.79, $69.20, and $14.                






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